United States v. Young, No. 20-3085 (8th Cir. 2021)
Annotate this CaseThe Eighth Circuit affirmed defendant's conviction and sentence for four counts related to unlawful possession of drugs and a gun. Under the facts of this case the court concluded that defendant cannot show that voir dire on race was constitutionally required and thus the court saw no reason why voir dire on implicit racial bias would be constitutionally required. The court explained that the district court's inquiries on racial bias went beyond the requirement to eliminate any reasonable possibility that racial or ethnic prejudice would influence the jury. Moreover, the district court was not required to inquire into potential implicit bias. The court also concluded that defendant's prior two Missouri drug convictions for the sale of cocaine base qualified as serious drug offenses under the Armed Career Criminal Act. Therefore, the district court did not err in applying the career criminal enhancement.
Court Description: [Kobes, Author, with Kelly and Grasz, Circuit Judges] Criminal case - Criminal law and sentencing. Under the facts presented defendant cannot show that voir dire on race was constitutionally required and in the absence of that threshold showing, inquiry on implicit racial bias was not constitutionally required; the district court's inquiries on racial bias went beyond the requirement to eliminate any reasonable possibility that racial or ethnic prejudice would influence the jury. and the district court was not required to inquire into potential implicit bias; defendant's two prior Missouri drug convictions were qualifying offenses under the Armed Career Criminal Act, and the district court did not err in applying the enhancement. Judge Kelly, concurring.
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